Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 1

Private and Confidential

Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition

January 10, 2016

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 

91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 

91.417(a)&(b) 

Dear Sir or Madam, 

I, Denny Ko-Wei Chang, am writing pursuant to the FAA Modernization and Reform Act of 2012 

and the procedures contained within 14 C.F.R. 11, to request that I, Denny Ko-Wei Chang, an 

owner and operator of small unmanned aircraft, be exempted from the Federal Aviation 

Regulations (“FARs”) listed below so that I, Denny Ko-Wei Chang, may operate my small ultra 

lightweight unmanned aircraft system (“UAS”) in commercially regulated airspace by the Federal 

Aviation Administration (“FAA”).

Following exemption and approval by the FAA, I, Denny Ko-Wei Chang, will primarily use my 

professionally built DJI Inspire 1, DJI Phantom 3 Professional, DJI Phantom 3 4K, DJI, Phantom 

3 Advanced, 3DR Solo, Yuneec TyphoonQ500 4K, Yuneec Typhoon G, and Yuneec Typhoon 

Q500+ UAS equipped with cameras for the following applications: Aerial photography, 

videography, and inspection for real estate, architecture, land surveying, crop monitoring, aerial 

mapping, engineering, special events to include but not limited to weddings, private or public 

parties/events, business advertising, promotional events, geological surveying, utilities, 

television, cinematography, news gathering, residential and commercial infrastructure 

inspection, utility inspections, search and rescue operations, national disaster, and UAS 

training.

My, Denny Ko-Wei Chang’s, exemption request would permit the operation of ultra lightweight, 

unmanned (i.e. piloted by remote control) UAS’s for the development of community and 

government use videos, permissible within property boundaries for individual homeowners and 

within in tightly controlled, limited airspaces predetermined in areas away from the general 

public, airports, heliports and vehicular traffic. Currently, similar lightweight, remote controlled 

UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in 

place to prevent catastrophes. Furthermore, it is my intent to assist future FAA safety protocols 

and regulations exclusive to lightweight UAS's for specific video and photography usage by 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 2

sharing information with the FAA as I, Denny Ko-Wei Chang, record flight data and other 

pertinent information gained through permitted flight operations. 

In addition, granting my, Denny Ko-Wei Chang’s, exemption request will comply with the 

Secretary of Transportation’s (FAA Administrator’s) instructions to not only integrate UAS's into 

the national airspace system, but to “...establish requirements for the safe operation of such 

aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act 

specific to the use of UAS's for real estate/Realtor purposes, educational videos, Search and 

Rescue, land/trusts inspections, agricultural field monitoring, film/video productions, motion 

picture film operations and television, and structure inspections, to aid state and local agencies. 

Further I, Denny Ko-Wei Chang, will conduct my operations in compliance with the protocols 

described herein or as otherwise established by the FAA. For the reasons stated below, I, 

Denny Ko-Wei Chang, respectfully request the grant of an exemption allowing me to operate 

ultra lightweight, remote controlled UAS’s to aid academic community awareness, to 

benefit/stimulate attraction,and to enhance personal and public video feeds. A grant that will 

ultimately allow UAS’s to play a more positive role in our local community by increasing 

employment opportunities, heightening security measures and decreasing government 

expenditures by reducing the need for heavier manned aircraft, containing costly, combustible 

fuel (a potential public hazard in and of itself). 

I. Contact Information:

Denny Ko-Wei Chang

3701 Knollcroft St

Easton, PA 18045

Phone: 314-662-1237

Email: bell206pilot@hotmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which 

Denny Ko-Wei Chang Requests Exemption are: 

14 CFR 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91, et seq

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

III. The Extent of relief Denny Ko-Wei Chang Seeks and the Reason He Seeks Such 

Relief: 

I, Denny Ko-Wei Chang, submit this application in accordance with the Reform Act, 112 P.L. 95 

§§ 331-334, seeking relief from any currently applicable FARs operating to prevent me, Denny 

Ko-Wei Chang, contemplated commercial cinematic, academic and other flight operations within

the national airspace system. The Reform Act in Section 332 provides for such integration of 

civil unmanned aircraft systems into our national airspace system as it is in the public’s interest 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 3

to do so. My, Denny Ko-Wei Chang’s, ultra lightweight UAS meets the definition of “small 

unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light 

weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra 

lightweight UAS prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such craft. Thereby, providing direct experience and valuable 

information for formal regulation that can be administered uniformly to all related UAS aerial 

video and photography. The Reform Act guides the Secretary in determining the types of UAS's 

that may operate safely in our national airspace system. Considerations include: 

 The weight, size, speed and overall capabilities of the UAS's

 Whether the UAS will be operated near airports or heavily populated areas

 Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a)

Each of these items reflect in favor of an exemption for me, Denny Ko-Wei Chang. My UAS’s 

utilize eight or less rotating propellers for balance, control and stability. My UAS’s are equipped 

with the following via video and data telemetry:

1) Altimeter 

2) Attitude indicator 

3) Ground speed indicator 

4) Magnetic compass 

5) Heading indicator 

6) Vertical speed indicator 

7) Course deviation indicator 

8) Radio magnetic indicator 

9) GPS location 

10) Battery consumption and battery left with approximate time. 

11) Loiter and circle mode

12) Auto safety or RTL (Return To Launch) 

13) Auto landing technology

Each UAS weighing less than 55 pounds; Including camera(s) with or without gimbal (a camera 

stabilizer). I, Denny Ko-Wei Chang, considers safety as foremost with each flight. My small 

unmanned aircraft is designed to hover in place, circle in a specific place or loiter via GPS and 

can be operated in winds up to 30.4 knots (35mph). For safety, stability and fear of financial loss 

I will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS 

mode that allows my UAS to hover/circle in place or land when radio controls are released. 

I, Denny Ko-Wei Chang, will fly with the mode safest to complete the videos for aerial 

videography/photography and have the ability to choose the safest, most reliable and stable 

mode to prevent accident and hazard. When pilot communication from the radio control is lost, 

UAS is designed slowly descend to point of takeoff and or to land at point of launch after 

ascending to a pre-set altitude to ensure the UAS will clear any obstacles that may be between 

the takeoff point and the current position of the UAS. 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 4

I, Denny Ko-Wei Chang, will not operate my UAS near airports, hospitals nor police heliports, 

and do not operate near areas where general public is within fifty to one hundred (50-100) yards 

depending on location, conditions and weather. I am constantly on alert for any manned aircraft 

(police/medical helicopters, etc.) and prepared to land/abort immediately to the nearest and 

safest ground point should a manned aircraft approach my location or I suspect manned aircraft 

may approach near my location. My UAS’s are capable of vertical and horizontal operations, 

and are flown only within my line of sight, as the remote control pilot. My UAS's are also flown 

with a second operator who aids in watching for any obstacles, including manned aircraft, within 

the flight zone of the UAS. Utilizing battery power rather than combustible fuels, flights generally 

last between three to twenty-five minutes, with an altitude under one-hundred and fifty feet. 

Smart Modes includes position hold, self-leveling, altitude command, GPS, return home feature, 

and safety control to return home or land in the event of communication interruption between 

RC transmitter and UAS.

I, Denny Ko-Wei Chang, utilize a fresh fully charged battery with each flight as a safety 

precaution; full flight time limit for each battery is eight to thirty minutes as tested. I do not 

operate my UAS at or below manufacturer recommend minimum charge levels for operation; 

preferring to remain well within a safe operating range to insure adequate communication 

between radio control and UAS to eliminate potential for crash, loss of control or hazard. 

Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level 

of operation. I do not believe in taking risk that may cause a crash, that could create hazard to 

the public/property/manned aircraft, and have no desire to lose an investment. I will clock 

numerous practice flights in remote areas simulating flights for future commercial use to gain 

familiarization with the characteristics of this specific UAS's performance under different 

temperature and weather conditions. I also practice computerized simulated flights to maintain 

adequate skills and response reflex time. All for the sake of safety. 

I, Denny Ko-Wei Chang, am extremely cautious when operating my UAS/ultra lightweight 

unmanned aircraft and will not “create a hazard to users of the national airspace system or the 

public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within 

Congress’s contemplated safety zone when it promulgated the Reform Act and the 

corresponding directive to integrate UAS's into the national airspace system. Denny Ko-Wei 

Chang’s UAS has a demonstrable safety record and does not pose any threat to the general 

public or national security. 

IV. How Denny Ko-Wei Chang’s Request Will Benefit the Public As A Whole: 

Aerial videography for geographical awareness, education, search and rescue, land 

management, structure inspections and for real estate marketing has been around for a long 

time through manned fixed wing aircraft and helicopters. For small budget companies, average 

homeowners and property owners the expense of such aerial videography is cost prohibitive. 

Only large companies and high end realtors or luxury homeowners can afford to absorb such 

expense; depriving non-luxury owners and lower budget companies from a valuable marketing 

tool. My, Denny Ko-Wei Chang's, UAS's size and lack of combustible fuel pose a lower risk to 

the public. Congress has already proclaimed that it is in the public’s interest to integrate 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 5

commercially flown UAS's into the national airspace system, hence the passing of the Reform 

Act. Granting my, Denny Ko-Wei Chang,’s, exemption request furthers the public interest 

through academic/visual awareness of the geographical benefits in and around the United 

States. My ultra light weight UAS is battery powered and creates no emissions that can harm 

the environment. Permitting me, Denny Ko-Wei Chang, to immediately fly within national air 

space furthers economic growth. Granting my exemption request substantially furthers the 

economic impact for the United States for companies looking to relocate or build as well as 

individuals looking to relocate for career advancement through academic and geographical 

awareness. Both of which serve as a stimulus to the community. 

V. Reasons Why Denny Ko-Wei Chang’s Exemption Will Not Adversely Affect Safety

Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

My, Denny Ko-Wei Chang’s, exemption will not adversely affect safety. Quite the contrary, for 

the reasons stated permitting me, Denny Ko-Wei Chang, to log more flight time in FAA 

controlled airspace, with communication with the FAA, will allow me to contribute to the 

innovation and implementation of new and novel, as of yet undiscovered safety protocols for 

realtors, land and structured owners. For development in cooperation with the FAA. In addition I,

Denny Ko-Wei Chang, submit the following representations of enhancements to current aerial 

videography and photography: 

 My UAS’s weigh less than 55 pounds (maximum weight including an integrated ultralight weight camera)

 I operate my UAS well below 200 feet 

 I operate my UAS for a maximum of 30 minutes per flight

 I land my UAS prior to manufacturer recommended minimum level of battery power

 I pilot my UAS through remote control only by line of sight; and have live video feed for a 

secondary pilot to monitor video recording

 I receive a live telemetry feed from my UAS during all flights which include remaining 

battery voltage, distance, altitude, and any anomalies that may occur during flight

 My UAS’s Command and Control utilizes spread spectrum 2.4Ghz-2.485Ghz 

frequencies in accordance with CFR 47, Part 15 for model aircraft use

My UAS’s have a GPS controlled flight controller- a flight safety feature whereby it hovers or 

circles and then lands at the GPS takeoff point if communication with the remote control pilot 

is lost; I actively record and analyze flight data through flight controller app to constantly update 

and enhance safety protocols; I only operate in reasonably safe environment that are strictly 

controlled, are away from power lines, elevated lights, airports and actively populated areas; I 

conduct extensive preflight inspections and protocol, during which safety carries primary 

importance; I always obtain all necessary permissions prior to operation; and I have procedures 

in place to abort flights in the event of safety breaches or potential danger. 

My, Denny Ko-Wei Chang’s, safety protocols provide a level of safety equal to or exceeding 

existing rules. It is important to note that absent the integration of commercial UAS into our 

national airspace system, helicopters are the primary means of aerial video and photography for 

community awareness, real estate, structured inspections, land management and search and 

rescue. UAS's carry no people on board and I only operates my UAS in specific areas away 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 6

from mass populations. There is no fuel on board a UAS and thus the potential for fire or 

explosions is greatly diminished. The small size and extreme maneuverability of my UAS allow 

me to remotely pilot away from and avoid hazards quickly and safely. Given its small size and 

weight, even when close enough to capture amazing images, my UAS need not be so close to 

the objects they are focused on through the technology and use of post editing software 

allowing pan and zoom. Accordingly, my UAS has been experimentally operated for 

familiarization/competency and will continue to operate at and above current safety levels. 

I, Denny Ko-wei Chang, propose to commercially operate UAS's pursuant to the following 

specific operation limitations:

1. The UAS must weigh less than 55 pounds (25kg), including energy source(s) 

and equipment

2. The UAS may not be flown at a speed exceeding a ground speed of 85 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operator's manual. 

All altitudes reported to ATC must be in feet AGL.

4. The UAS must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC's state driver’s 

license.

5. All operations must utilize a visual observer (VO). The VO may be used to 

satisfy the VLOS requirement, as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times.

6. If a discrepancy exists between these limitations and any procedure outlined 

elsewhere, the conditions and limitations herein take precedence and must be 

followed.

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe 

operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station, if utilized, must be 

included in the preflight inspection. All maintenance and alterations must be 

properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight in accordance with the 

operator's manual. The PIC who conducts the functional test flight must make 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 7

an entry in the UAS aircraft records of the flight.\The operator must follow the 

manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance

requirements must be established and identified in the operator's manual. At a 

minimum, the following must be included in the operator's manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)

j. Any other components as determined by the operator

9. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least 

a current state driver’s license. The PIC must also meet the flight review requirements 

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his/her pilot 

certificate.

10. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 

14 CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a 

UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS 

type (single blade or multirotor). Prior documented flight experience that was obtained 

in compliance with applicable regulations may satisfy this requirement. Training, 

proficiency, and experience-building flights can also be conducted under this grant of 

exemption to accomplish the required flight cycles and flight time. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered non-participants, and the PIC must operate the UAS with 

appropriate distance from non-participants in accordance with 14 CFR § 91.119.

11. Prior to operations conducted for the purpose of motion picture filming (or similar

operations), the PIC must have accumulated and logged, in a manner consistent with 

14 CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and 

model of UAS to be utilized for operations under the exemption and three take-offs 

and three landings in the preceding 90 days. Training, proficiency, experiencebuilding, and take-off and landing currency flights can be conducted under this grant 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 8

of exemption to accomplish the required flight time and 90 day currency. During 

training, proficiency, experience-building, and take-off and landing currency flights, all 

persons not essential for flight operations are considered non-participants, and the 

PIC must operate the UAS with appropriate distance from non-participants in 

accordance with 14 CFR § 91.119.

12. Prior to any flight operations authorized by this grant of exemption, the PIC and 

visual observer (VO) must have successfully completed a qualification process, as 

outlined in the operator’s manual. As this is a requirement stipulated by the operator, 

the test must be developed and implemented by a qualified person designated at the 

sole discretion of the operator. A record of completion of this qualification process 

must be documented and made available to the Administrator upon request.

13. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and -

qualified pilot must be successfully completed and documented. This documentation 

must be available for review upon request by the Administrator. Because the 

knowledge and airmanship test qualifications have been developed by the operator, 

and there are no established practical test standards that support a jurisdictional FAA 

FSDO evaluation and approval of company designated examiners, the petitioner will 

conduct these tests in accordance with the operator’s manual.

14. The UAS may not be operated directly over any person, except authorized and 

consenting production personnel, below an altitude that is hazardous to persons or 

property on the surface in the event of a UAS failure or emergency.

15. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting production personnel. At all times, those 

persons must be essential to the closed-set film operations. Because these 

procedures are specific to participating persons, no further FSDO or Aviation Safety 

Inspector (ASI) approval is necessary for reductions to the distances specified in the 

petitioner’s manuals. This is consistent with the manned aircraft procedures described 

in FAA Order 8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion Picture and 

Television Filming.

16. Regarding distance from non-participating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be 

involved and necessary for the filming production. This provision may be reduced to 

no less than 200 feet if it would not adversely affect safety and the Administrator has 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 9

approved it. For example, an equivalent level of safety may be determined by an 

aviation safety inspector’s evaluation of the filming production area to note terrain 

features, obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debris in the 

event of an accident. This is also consistent with the same FAA Order 8900.1, V3, C8, 

S1. 18. If the UAS loses communications or loses its GPS signal, the UA must return 

to a pre-determined location within the security perimeter and land or be recovered in 

accordance with the operator’s manual.

17. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in 

accordance with the operator’s manual.

18. The UAS must abort the flight in the event of unpredicted obstacles or emergencies 

in accordance with the operator’s manual.

19. Each UAS operation must be completed within 30 minutes flight time or with 25%

battery power remaining, whichever occurs first.

20. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations under this grant of

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation.

21. All aircraft operated in accordance with this exemption must be identified by 

serial number, registered in accordance with 14 CFR part 47, and have 

identification (N-Number) markings in accordance with 14 CFR part 45, Subpart 

C. Markings must be as large as practicable.

22. The operator must develop procedures to document and maintain a record of the 

UAS maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the UAS. 

These procedures must be added to the operator’s manual.

23. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins.

24. The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

25. The preflight inspection section in the operator’s manual must be amended to include 

the following requirement: The preflight inspection must account for all discrepancies, 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 10

i.e. inoperable components, items, or equipment, not covered in the relevant preflight 

inspection sections of the operator’s manual.

26. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements.

27. At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction 

over the area of proposed filming. The 3-day notification may be waived with the 

concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights

b. Name and phone number of the person responsible for the UAS filming 

production under this grant of exemption

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS.

d. Make, model and serial or N-number of the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the filming production 

event 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those who 

gave permission must be made available to the inspector upon request.

g. Signature of exemption-holder or representative

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation

28. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the 

PIC at the ground control station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request.

29. The UAS must remain clear and yield the right of way to all other manned operations 

and activities at all times (including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc.).

30. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). 

Flights under special visual flight rules (SVFR) are not authorized.

31. The UAS cannot be operated by the PIC from any moving device or vehicle.

32. The UAS may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

33. The UAS may not operate in Class B, C, or D airspace without written approval from 

the FAA. The UAS may not operate within 5 miles of the geographic center of a non-
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 11

towered airport as denoted on a current FAA-published aeronautical chart unless a 

letter of agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA. The letter 

of agreement with the airport management must be made available to the 

Administrator upon request.

34. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS-80) within 

24 hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight 

operations may not be conducted until the incident, accident, or transgression is 

reviewed by AFS-80 and authorization to resume operations is provided.

VI. A Summary The FAA May Publish in the Federal Register: 

The Specific Sections of Title 14 of the Code of Federal Regulations from which Denny Ko-Wei 

Chang requests exemption include14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 

61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. 

§ 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 

91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 

14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b). The size, weight and enclosed 

operational area of my UAS permits exemption from Part 21 because my, Denny Ko-Wei 

Chang’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. 

The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under 

both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of 

legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and proximity to areas such as airports 

and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) 

prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate 

will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level 

of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions 

to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

maintenance program that involves regular software updates and curative measures for any 

damaged hardware. Therefore, an equivalent level of safety will be achieved. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The 

size, weight and enclosed operational area of my, Denny Ko-Wei Chang’s, UAS permits 

exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 12

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 

of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability 

and proximity to areas such as airports and dense populations. My, Denny Ko-Wei Chang,’s, 

current and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on 

board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a safety/flight manual delineating 

areas of where safety can be defined. 

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor or controlled GPS “geofencing” 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety will be achieved by maintaining any such required certifications and registrations by 

me, Denny Ko-Wei Chang.

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain specifications. My UAS can be marked with the 

appropriate “N” number once this “N” number has been given.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 

61.113 (a) & (b), private pilots are limited to non-commercial operations. The UAS Pilot in 

Command must possess at least a sport pilot certificate and a driver's license. The PIC must 

also meet the flight review requirements specified in 14 CFR § 61.56 in which the PIC is rated 

on his/her pilot certificate as outlined in 14 C.F.R. § 61.

14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the 

operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain 

conditions. My UAS will never operate at an altitude greater than 200 feet AGL. I, Denny Ko-Wei 

Chang, will operate my UAS in safe areas away from public and traffic, providing a level of 

safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, 

weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be 

achieved.
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 13

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The 

above-cited Regulations require, amongst other things, aircraft owners and operators to “have 

[the] aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter. . . .”These Regulations only apply to aircraft with an 

airworthiness certificate. They will not, therefore, apply to my, Denny Ko-Wei Chang's, UAS. 

However, as a safety precaution I inspect my UAS before and after each flight. 

In summary, Denny Ko-Wei Chang seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 

14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 

C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 

14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. 

§§ 91.417 (a) & (b) to commercially operate my, Denny Ko-Wei Chang's, small unmanned 

vehicle/lightweight unmanned aircraft vehicle in community awareness, education, structural 

inspection, land management, search and rescue, and real estate operations. 

Granting my, Denny Ko-Wei Chang’s, request for exemption will reduce current risk levels and 

thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, 

lighter and more maneuverable than conventional video and photographic aircraft with much 

less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating 

potential public risk flying to and from established airfields. I, Denny Ko-Wei Chang, have been 

informally analyzing and recording flight information and will compile safety protocols and the 

implementation of a flight operations manual for usage that exceeds currently accepted means 

and methods for safe flight. Formal collection of information shared with the FAA will enhance 

the FAA's internal efforts to establish protocols for complying with the FAA Modernization and 

Reform Act of 2012. There are no personnel on board my, Denny Ko-Wei Chang’s, UAS. My, 

Denny Ko-Wei Chang’s, operation of my UAS, weighing less than 55 pounds and traveling at 

lower speeds within limited areas low to the ground will provide an equivalent level of safety as 

that achieved under current FARs. Accordingly I, Denny Ko-Wei Chang, respectfully request 

that the FAA grant my exemption request and am willing to cooperate in sharing information to 

benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted, 

Denny Ko-Wei Chang

3701 Knollcroft St.

Easton, PA 18045
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 14

Appendix

A Make and Model DJI Inspire 1

Manual Link https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en_

v2.0_1218.pdf

B Make and Model DJI Phantom 3 Professional

Manual Link https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_

User_Manual__V1.6.pdf

C Make and Model DJI Phantom 3 4K

Manual Link https://dl.djicdn.com/downloads/phantom_3_4k/en/Phantom_3_4K_User_

Manual_en_1.8.pdf

D Make and Model DJI Phantom 3 Advanced

Manual Link https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Advanced_Us

er_Manual__V1.6.pdf

E Make and Model 3DR Solo

Manual Link https://3dr.com/wp-content/uploads/2016/01/v8_01_05_16.pdf

F Make and Model Yuneec Typhoon Q500 4K

Manual Link https://www.yuneec.com/download/manuals/Typhoon%20Q500%204k-

%20User%20Manual%20V12302015.pdf

G Make and Model Yuneec Typhoon G

Manual Link https://www.yuneec.com/download/manuals/Typhoon-G-ConnectorVersion-User-Manual-0918.pdf

H Make and Model Yuneec Typhoon Q500+

Manual Link https://www.yuneec.com/download/manuals/typhoon_q500plus_user_man

ual_v2.0.pdf

I Personal Protocols

j Record of Flight

This Appendix includes links to UAS manufacturer's manuals, maintenance instructions, and 

illustrated parts catalogs. Information regarding design, aircraft performance, fail-safe 

features, operating limitations, normal and emergency procedures, and maintenance and 

inspection procedures is contained within the manuals and supplemental information 

documents listed.
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 15

Appendix A

AIRCRAFT SPECS

DJI Inspire 1

Model T600

Weight (Battery Included) 2935 g

Hovering Accuracy (GPS mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea 

Level 4500 m (Default altitude limit: 120 m above takeoff point)

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Motor Model DJI 3510H

Propeller Model DJI 1345T

Indoor Hovering Enabled by default

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438x451x301 mm

Power Spectral Density 9.06mW/MHz

CAMERA

Name X3

Model FC350

Total Pixels 12.76M

Effective Pixels 12.4M

Image Max Size 4000x3000

ISO Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed 8s - 1/8000s

FOV (Field of View) 94°

CMOS Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion 

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames 

at 0.7EV Bias

Time-lapse
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 16

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate of Video Storage 60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range 0° to 40° C

CHARGER

Model A14-100P1A

Voltage 26.3 V

Rated Power 100 W

BATTERY (OPTIONAL)

Name Intelligent Flight Battery

Model TB48

Capacity 5700 mAh

Voltage 22.8 V

Battery Type LiPo 6S

Energy 129.96 Wh

Net Weight 670 g

Operating Temperature Range -10° to 40° C

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range 0° to 40° C

Max Charging Power 180 W

DJI GO APP

Mobile Device System 

Requirements iOS 8.0 or later, Android 4.1.2 or later

Supported Mobile Devices

* Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, 

iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 

2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, 

iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is 

optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus.

* Compatible with Samsung tabs 705c, Samsung S6, 

Samsung S5, Samsung NOTE4, Samsung NOTE3, 

Google Nexus 9, Google Nexus 7 II, Ascend Mate7, 

Huawei P8 Max, Nubia Z7 mini,Sony Xperia Z3, MI 3, MI 

PAD, Smartisan T1.

*Support for additional Android devices available as 

testing and development continues.
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 17

Appendix B

AIRCRAFT SPECS

DJI Phantom 3 Professional

Weight (including battery and 

propellers) 1280 g

Hover Accuracy

· Vertical: +/- 0.1 m (when Vision Positioning is 

active) or +/- 0.5 m

· Horizontal: +/- 1.5 m

Diagonal size (including propellers) 590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Max Speed 16 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level 6000 m (Default altitude limit: 120 m above takeoff point)

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

CAMERA

Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total 

pixels: 12.76 M)

Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus 

at ∞

ISO Range 100-3200 (video) 100-1600 (photo) 

Shutter Speed 8s -1/8000s

Image Max Size 4000 x 3000

Still Photography Modes

· Single Shot

· Burst Shooting: 3/5/7 shots

· Auto Exposure Bracketing (AEB): 3/5

· Bracketed Frames at 0.7EV Bias

· Time-lapse

Video Recording Modes

Phantom 3 Advanced

· 2.7K: 2704 x1520p 24/25/30 (29.97)

· FHD: 1920x1080p 24/25/30/48/50/60

· HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required

Max Bitrate of Video Storage

Phantom 3 Advanced

40 Mbps

Supported File Formats

· FAT32/exFAT

· Photo: JPEG, DNG

· Video: MP4, MOV (MPEG-4 AVC/H.264)
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 18

Operating Temperature 0°C to 40°C

BATTERY CHARGER

Voltage 17.4 V

Rated Power

Phantom 3 Advanced

· 57 W

GIMBAL

Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

REMOTE CONTROLLER

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance

Up to 5 km or 3.1 miles (unobstructed, free of 

interference) when FCC compliant

Up to 3.5 km or 2.1 miles (unobstructed, free of 

interference) when CE compliant

Video Output Port USB

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone

Receiver Sensitivity (1%PER) -101 dBm ±2 dBm

Transmitter Power (EIRP)

· FCC: 20 dBm

· CE: 16 dBm

Working Voltage 1.2 A @7.4 V

INTELLIGENT FLIGHT BATTERY

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 23 minutes 

Operating Temperature -10°C to 40°C

Max Charging Power 100 W

VISION POSITIONING

Max Velocity Less than 8 m/s (when 2 m above ground)

Altitude Range 50 cm-300 cm

Operating Range 50 cm-300 cm

Operating Environment Surface with clear pattern and adequate lighting (Lux > 

15)

APP / LIVE VIEW

Mobile App DJI GO

EIRP 100mW
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 19

Power Spectral Density 6.9mW/MHz

Live View Working Frequency 2.4GHz ISM

Live View Quality 720P @ 30fps (depending on conditions and mobile 

device)

Latency 220ms (depending on conditions and mobile device)

Required Operating Systems

· iOS 8.0 or later

· Android 4.1.2 or later

Recommended Devices

· iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, 

iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 2 Wi-Fi 

+ Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad 

mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is 

optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus. 

· Android: Samsung tabs 705c, Samsung S6, 

Samsung S5, Samsung NOTE4, Samsung NOTE3, 

Google Nexus 9, Google Nexus 7 II, Ascend Mate7, 

Huawei P8 Max, Nubia Z7 mini, Sony Xperia Z3, MI 3, 

MI PAD, Smartisan T1. *Support for additional Android 

devices available as testing and development continues.
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 20

Appendix C

AIRCRAFT SPECS

DJI Phantom 3 4K

Weight (Including Battery And 

Propellers) 1280 g

Hover Accuracy

· Vertical: +/- 0.1 m (when Vision Positioning is 

active); +/- 0.5 m

· Horizontal:+/- 1.5 m

Diagonal Size (Including Propellers) 590 mm

Max Asecnt Speed 5 m/s

Max Descent Speed 3 m/s

Max Speed 16 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level 6000 m (Software altitude limit: 120 m above takeoff 

point)

Operating Temperature 0°C to 40°C

GPS Mode GPS

CAMERA

Sensor Sony EXMOR 1/2.3" CMOS

Effective pixels 12.4M (total pixels: 12.76M)

Lens

· FOV 94° 20 mm (35 mm format equivalent) f/2.8

· Focus at ∞

ISO Range

· 100-3200 (video)

· 100-1600 (photo)

Shutter Speed 8s - 1/8000s

Max Image Size 4000 x 3000

Still Photography Modes

· Single Shot

· Burst Shots: 3/5/7 shots

· Auto Exposure Bracketing(AEB): 3/5 shots

· Bracket Frames at 0.7EV Bias

· Time-lapse

Video Recording Modes

· UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

· FHD: 1920x1080p 24/25/30/48/50/60

· HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types

· Micro-SD 

· Max capacity: 64 GB. Class 10 or UHS-1 rating 

required

Max Bitrate of Video Storage 60 Mbps

Supported File Formats

· FAT32/exFAT

· Photo: JPEG, DNG
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 21

· Video: MP4,MOV (MPEG-4 AVC/H.264)

Operating Temperature 0°C to 40°C

BATTERY CHARGER

Voltage 17.5 V

Rated Power 57 W

GIMBAL

Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

REMOTE CONTROLLER

Operating Frequency

· 5.725 GHz – 5.825 GHz

· 922.7 MHz – 927.7 MHz (Japan)

Max Distance

· FCC: 1200m

· CE: 500m(unobstructed, free of 

interference,120m above takeoff point)

Operating Temperature 0°C- 40°C

Battery 2600 mAh LiPo18650 2S

Mobile Device Holder For tablet or phone (phone recommended)

Transmitter Power (EIRP)

· FCC: 19 dBm

· CE: 14 dBm

Working Voltage 300 mA @7.4 V

INTELLIGENT FLIGHT BATTERY

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 25 minutes

Operating Temperature -10°C to 40°C

Max Charging Power 100 W

VISION POSITIONING

Max Velocity Less than 8 m/s (when 2 m above ground)

Altitude Range 50 cm - 300 cm

Operating Range 50 cm - 300 cm

Operating Environment Surface with clear pattern and adequate lighting 

(Lux>15)

APP / LIVE VIEW

Mobile App DJI GO

Live View Quality 480P @ 30fps 

Required Operating Systems · iOS 8.0 or later
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 22

· Android 4.1.2 or later 

Recommended Devices

· ios: iPhone 5s、iPhone 6、 iPhone 6 Plus、 iPad 

Air、 iPad Air Wi-Fi + Cellular、 iPad mini 2、 iPad mini 

2 Wi-Fi + Cellular、 iPad Air 2、iPad Air 2 Wi-Fi + 

Cellular、 iPad mini 3 及 iPad mini 3 Wi-Fi + Cellular. 

This app is optimized for iPhone 5s, iPhone 6, and 

iPhone 6 Plus

· Android: Samsung tabs 705c、Samsung 

S6、Samsung S5、Samsung NOTE4、Samsung 

NOTE3、Google Nexus 9、Google Nexus 7 II、Ascend 

Mate7、Nubia Z7 mini、SONY Z3 EXPE、MI 3、MI 

PAD

*Support for additional Android devices available as 

testing and development continues.

WI-FI

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance

· FCC: 1200m

· CE: 500m(unobstructed, free of 

interference,120m above takeoff point)

Transmitter Power (EIRP)

· FCC: 27 dBm

· CE: 20 dBm
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 23

Appendix D

AIRCRAFT SPECS

DJI Phantom 3 Advanced

Weight (including battery and 

propellers) 1280 g

Hover Accuracy

· Vertical: +/- 0.1 m (when Vision Positioning is 

active) or +/- 0.5 m

· Horizontal: +/- 1.5 m

Diagonal size (including propellers) 590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Max Speed 16 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level 6000 m (Default altitude limit: 120 m above takeoff point)

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

CAMERA

Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total 

pixels: 12.76 M)

Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus 

at ∞

ISO Range 100-3200 (video) 100-1600 (photo) 

Shutter Speed 8s -1/8000s

Image Max Size 4000 x 3000

Still Photography Modes

· Single Shot

· Burst Shooting: 3/5/7 shots

· Auto Exposure Bracketing (AEB): 3/5

· Bracketed Frames at 0.7EV Bias

· Time-lapse

Video Recording Modes

Phantom 3 Advanced

· 2.7K: 2704 x1520p 24/25/30 (29.97)

· FHD: 1920x1080p 24/25/30/48/50/60

· HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required

Max Bitrate of Video Storage

Phantom 3 Advanced

40 Mbps

Supported File Formats · FAT32/exFAT
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 24

· Photo: JPEG, DNG

· Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature 0°C to 40°C

BATTERY CHARGER

Voltage 17.4 V

Rated Power

Phantom 3 Advanced

· 57 W

GIMBAL

Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

REMOTE CONTROLLER

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance

Up to 5 km or 3.1 miles (unobstructed, free of 

interference) when FCC compliant

Up to 3.5 km or 2.1 miles (unobstructed, free of 

interference) when CE compliant

Video Output Port USB

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone

Receiver Sensitivity (1%PER) -101 dBm ±2 dBm

Transmitter Power (EIRP)

· FCC: 20 dBm

· CE: 16 dBm

Working Voltage 1.2 A @7.4 V

INTELLIGENT FLIGHT BATTERY

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 23 minutes 

Operating Temperature -10°C to 40°C

Max Charging Power 100 W

VISION POSITIONING

Max Velocity Less than 8 m/s (when 2 m above ground)

Altitude Range 50 cm-300 cm

Operating Range 50 cm-300 cm

Operating Environment Surface with clear pattern and adequate lighting (Lux > 

15)

APP / LIVE VIEW
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 25

Mobile App DJI GO

EIRP 100mW

Power Spectral Density 6.9mW/MHz

Live View Working Frequency 2.4GHz ISM

Live View Quality 720P @ 30fps (depending on conditions and mobile 

device)

Latency 220ms (depending on conditions and mobile device)

Required Operating Systems

· iOS 8.0 or later

· Android 4.1.2 or later

Recommended Devices

· iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, 

iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 2 Wi-Fi 

+ Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad 

mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is 

optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus. 

· Android: Samsung tabs 705c, Samsung S6, 

Samsung S5, Samsung NOTE4, Samsung NOTE3, 

Google Nexus 9, Google Nexus 7 II, Ascend Mate7, 

Huawei P8 Max, Nubia Z7 mini, Sony Xperia Z3, MI 3, 

MI PAD, Smartisan T1. *Support for additional Android 

devices available as testing and development continues.
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 26

Appendix E

AIRCRAFT SPECS

3DR Solo

Cameras: Compatible with GoPro® HERO3, 3+ and 4; optimized for HERO3+ and 4

Streaming video quality: 720p

Flight time: 25 minutes; 20 minutes with payload*

Range: .5 miles** (.8 km)

Max speed: 55 mph (89 km/h)

Max ascent speed: 10 m/s in stabilize mode; 5 m/s in “fly” mode

Max descent speed: ditto

Max payload: 420 g

Max altitude: 400 ft per FAA regulation, user adjustable (122 m)

Motors: 880 kV

Propellers: 10′′ diameter 4.5′′ pitch self-tightening (24 cm diameter 144 cm pitch); glass-reinforced nylon

Autopilot: Pixhawk 2

Software: APM:Copter

Communication: 3DR Link secure WiFi network

Frequency: 2.4 GHz

Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal

Dimensions: 10 in. tall (25 cm), 18 in. (46 cm) motor-to-motor

Flight battery: Lithium polymer 5200 mAh 14.8 Vdc

Battery charge time: ~1.5 hours

Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion

App requirements: iOS 8.0 or later / Android 4.3 or later

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style and pilot 

skill. Listed flight time applies to elevations less than 2,000 ft above sea level.

**Depending on environmental conditions; controller is expandable, allowing us or third parties to amp up 

the range in the future.

Solo Smart Battery:

Rechargeable lithium polymer (Li-Po)

5200 mAh

14.8 Vdc

Weight: 1 lb. (.5 kg)

Solo Gimbal:

Three-axis stabilization

Fully compatible with 3DR Solo and GoPro HERO3+ and HERO4; camera charging and stabilization only 

with HERO3

HDMI video output

Wireless software upgrade through Solo

Controllable range: 0° to -90° pitch
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 27

Appendix F

AIRCRAFT SPECS

Yuneec Typhoon Q500 4K

Flight Time up to 25 minutes

Weight with Battery and Payload 60.0 oz (1700g)

Weight without Battery and Payload 40.0 oz (1130g)

Battery 5400mAh 3S 11.1V LiPo (included)

Charger 3S 11.1V LiPo DC Balancing Smart 

Charger with AC Adapter (included)

Transmitter 10-channel 2.4GHz with 5.8GHz video 

downlink (included)

3 Flight Modes Smart (Follow Me and Watch Me), Angle 

and Home

Maximum Flying Height Default 122m (400ft) above Ground Level 

(Adjustable via the Typhoon GUI)

Maximum Rotation Rate 65°/s

Maximum Roll Angle 35°

Operating Temperature Range −5°C to 80°C

Radio Control Frequency Band 2.4GHz

Max. Descent Speed 2m/s

Max. Flight Speed 17mph / 27 kph (Angle Mode), 22mph / 35 

kph (Follow Me/Watch Me)

Gimbal Camera 

Type CGO3

Weight 6.9oz (195g)

Focusing System Aerial Optimized Fixed Focus

Field of View 115°

Video Transmission Range

FCC Compliance: Up to 600m (1968.5 ft)

CE Compliance: Up to 300m (984.252 ft) 

with ST10

Video Resolution

UHD: 4K at 30FPS, 2.7K at 30FPS, 2.5K at 

30FPS — FULL HD: 1080p at 

24/25/30/48/50/60/120FPS 

Photo Resolution 12 Megapixels

Storage (memory) microSD Class 10 ~ 4 to 128 GB

Control Angle Accuracy ±0.02°

White Balance Automatic or manual settings

Transmission Band 5.8GHz.

Input/Operating Voltage 12V
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 28

Working Temperature −10°C–50°C

Storage Temperature −20°C–60°C

Angular Vibration Range ±0.02°

Control Range Pitch: between −90° and 0°

Microphone Yes

Camera Lens 14mm f/2.8 – No distortion

Sensor 1/2.3′′ CMOS

Personal Ground Station 

Dimensions

Type ST10+

Operating System AndroidTM

Number of Channels 10

Control Transmission Range (Optimum 

Conditions)

FCC Compliance: Up to 800m (2624.67 ft) 

CE Compliance: Up to 400m (1312.34 ft) 

Warning: You Must Follow Local Laws and 

Maintain Visual Line of Sight of Aircraft at 

All Times

Robust Radio Control Modulation Yuneec Protocol

Video Link Frequency Band 5.8GHz

Video Transmission Range (Optimum 

Conditions)

FCC Compliance: Up to 600m (1968.5 ft) 

CE Compliance: Up to 300m (984.252 ft) 

Warning: You Must Follow Local Laws and 

Maintain Visual Line of Sight of Aircraft at 

All Times

Flight Systems Telemetry Data On Screen 

Display Yes

LED Backlit LCD Screen Capacitive Multi-touch 5.5′′

Tactile (Vibrating) and Audible Feedback Yes

Built-in LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh

Screen Resolution 854 × 480px

Camera Settings

White balance, light exposure, ISO, shutter 

speed, video resolution, FPS, record video, 

take pictures

CGO Steadygrip V3 

Dimensions

Weight (without camera and gimbal) 13.9 oz (395g)

Compatible camera CGO2GB / CGO2+ / CGO3 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 29

Appendix G

AIRCRAFT SPECS

Yuneec Typhoon G

Flight Time up to 25 minutes

Weight with Battery and Payload 60.0 oz (1700g)

Weight without Battery and Payload 40.0 oz (1130g)

Battery 5400mAh 3S 11.1V LiPo (included)

Charger 3S 11.1V LiPo DC Balancing Smart 

Charger with AC Adapter (included)

Transmitter 10-channel 2.4GHz with 5.8GHz video 

downlink (included)

3 Flight Modes Smart (Follow Me and Watch Me), Angle 

and Home

Maximum Flying Height Default 122m (400ft) above Ground Level 

(Adjustable via the Typhoon GUI)

Maximum Rotation Rate 65°/s

Maximum Roll Angle 35°

Operating Temperature Range −5°C to 80°C

Radio Control Frequency Band 2.4GHz

Max. Descent Speed 2m/s

Max. Flight Speed 8m/s

GB203 Gimbal 

Dimensions

Weight 8.1 oz (230g)

Pitch mechanical range -120° ~ +60°

Yaw mechanical range -45° ~ +45°

Roll mechanical range -45° ~ +45°

MK58 Digital Video Downlink 

Dimensions (without antenna)

Weight 1.27oz (36g)

Compatible Camera Hero 3,Hero 3+,Hero 4 black/silver

Working Voltage 5V (±0.5V)

Working Current 1A

Personal Ground Station 

Dimensions

Type ST10+

Operating System AndroidTM
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 30

Number of Channels 10

Control Transmission Range (Optimum 

Conditions)

FCC Compliance: Up to 800m (2624.67 ft) 

CE Compliance: Up to 400m (1312.34 ft) 

Warning: You Must Follow Local Laws and 

Maintain Visual Line of Sight of Aircraft at 

All Times

Robust Radio Control Modulation Yuneec Protocol

Video Link Frequency Band 5.8GHz

Video Transmission Range (Optimum 

Conditions)

FCC Compliance: Up to 600m (1968.5 ft) 

CE Compliance: Up to 300m (984.252 ft) 

Warning: You Must Follow Local Laws and 

Maintain Visual Line of Sight of Aircraft at 

All Times

Flight Systems Telemetry Data On Screen 

Display Yes

LED Backlit LCD Screen Capacitive Multi-touch 5.5′′

Tactile (Vibrating) and Audible Feedback Yes

Built-in LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh

Screen Resolution 854 × 480px

Camera Settings

White balance, light exposure, ISO, shutter 

speed, video resolution, FPS, record video, 

take pictures

SteadyGrip 

Dimensions

Weight (without camera and gimbal) 13.9 oz (395g)

GoPro® Hero 3/Hero 3+/Hero 4 black/silver
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 31

Appendix H

AIRCRAFT SPECS

Yuneec Typhoon Q500+

Flight Time Up to 25 Minutes

Dimension 16.5x16.5x8.3in (420x420x210mm)

Diagonal Length Without Rotor Blades 22.2in (565mm)

Propeller/Main Rotor Diameter 13.0in (330mm)

Weight Without Battery and Payload 40.0oz (1130g)

Battery 5400mAh 3S 11.1V LiPo (included)

Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter 

(included)

Transmitter 10-channel 2.4GHz with 5.8GHz video downlink (included)

3 Flight Modes Smart, Angle and Home Modes

Maximum Flying Height Default 122m (400ft) Above Ground Level (Adjustable via the 

Q500 GUI)

Maximum Rotation Rate 65°/s

Maximum Roll Angle 35°

Operating Temperature Range -5°C to 80°C

Camera Gimbal System

Dimension 4.5x1.4x2.9in (115x135x74mm)

Weight 6.5oz (185g

Focusing System Aerial Optimized Fixed Focus

Field of View 130°

Video Transmission Range FCC Compliance: Up to 600m (1968.5 ft)

Video Transmission Range CE Compliance: Up to 300m (984.25 ft) with ST10

Video Resolution FULL HD 1080p - Adjustable 60, 50 or 48 FPS

Photo Resolution 16 Megapixels

Storage (memory) microSD Class 10, 4 to 128GB

Control Angle Accuracy ±0.02°

White Balance Automatic White Balance

Transmission Band 5.8GHz

Input/Operating Voltage 7.0V to 14.0V DC

Working Temperature 0°C-50°C

Storage Temperature -20°C to 60°C

Angular Vibration Range ±0.02°

Control Range Pitch: between -90° and 0° 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 32

Personal Ground Station

Control Transmission Distance/Range 

(Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft)

CE Compliance: Up to 400m (1312.34 ft)

Robust Radio Control Modulation Yuneec Protocol

Video link Frequency Band 5.8GHz

Video Transmission Distance/Range 

(Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft)

CE Compliance: Up to 300m (984.252 ft)

Flight Systems Telemetry Data On 

Screen Display (OSD) Yes

LED Backlit LCD Screen Capacitive Multi-Touch 5.5”

Tactile (Vibrating) and Audible Feedback Yes

Built-In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh

Charger Auto-Charge Mode via Micro-B USB Cable with AC to 5V DC 

USB Power Supply (Included)
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 33

Appendix I

Personal Protocols

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. As such, safety protocols and controls must be 

implemented through pre-flight preparation and during flight. 

Pre-Flight Protocol: 

 Check batteries with voltage meter to insure fully charged and ready for use. 

 Inspect batteries for damage or leakage that may affect proper operation. 

 Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion 

or unmanageable/uncontrolled flight. 

 Check all GPS and Telemetry connections prior to flight. 

 Check weather forecasts for wind advisory or other conditions that my impact flight. 

 Consult Sky Vector aeronautical Charts (Skyvector.com)for airport vicinity and flight 

paths of possible air traffic.

 Contact respective airport to advise of estimated flight time, estimated flight duration, 

estimated elevation of flight, and any other pertinent information. 

 Inspect flight area for 

o Vicinity of public safety helipads/heliports

o Vicinity of medical helipads/heliports 

o Vicinity of light poles vicinity or utility wires 

o Vicinity of trees flocks of birds that may cause interference and potential flight 

impact Vicinity of any elevated obstructions that may pose potential flight hazard 

o Vicinity of roadways with moderate to heavy traffic that can be distracted public 

Gatherings that may attract viewers optional point of control for best visual site of 

UAS while in flight 

o Emergency landing areas 

 Takeoff and landing 

o Inspect area for best and safest point of takeoff and landing 

o If in a subdivision or area that is within 150 feet of a residential street, post 

warning sign(s)/stand(s) "Attention Aerial Photography In Progress. Remain 

Back 150 Feet " 

Flight Protocol:

 Takeoff and land from same location (have alternate landing areas in case of 

emergencies) remain alert to birds, sound or aircraft, curious public, and approaching 

vehicles do not allow anyone to engage in conversation or distract the remote control 

pilot restrict flight to minimal elevation sufficient to acquire desired results remained 

prepared for emergency landing at all times pay attention to flight time – warning meter 

for low voltage. 

 Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and 

shut down propulsion immediately following landing – priority of disconnecting batteries 
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 34

Post Flight Protocol: 

 Disconnect battery to prevent accidental activation of propulsion system 

 Secure UAS in a safe location 

 Remove all warning signs from public access areas 

Emergency or Suspected Hazard: 

 Immediately land UAS at safest and closet ground location in the event:

o Manned aircraft is heard or seen in vicinity of flight 

o There is a public gathering within established safety boundary wanting to 

observe flight 

o Pilot is being distracted from focusing on flight and safety 

o Sudden change in weather (wind bursts) 

o Sudden increase in vehicular traffic in vicinity of flight 

o Birds enter into proximity of flight 

o Any sudden unsafe event that can cause collision, distraction or interruption of 

control 

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. 

Maintaining a record of safe flight for FAA request and for determining future UAS safety 

protocols is imperative. 

Additional Operation/Maintaining 

Before each flight:

 Check all hardware to ensure it is securely tightened.

 Check that the motor is level and locked in place.

 Check the propeller to ensure it is tight and there are no visible signs of cracks, stress,

 Check all wiring to motors, motor controllers, batteries, and flight controller for signs of

chafing and/or cracking.

 Check all navigational lighting for security and proper operation.

After 45 hours of flight

 Remove and check all motors and motor mounts for signs of wear and tear. Replace 

as necessary.

 Remove motor controllers and visually inspect and check for damage. Replace as 

necessary.

 Remove flight controllers and visually inspect and check for damage. Replace as 

necessary.

 Remove propellers and visually inspect for damage and/or chips. Replace if propeller 

is questionable.

 Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

 Check for updates to flight controller firmware. If available, install and perform a 

minimum of 15 test flights before conducting commercial work.
Denny Ko-Wei Chang, Easton, PA - Section 333 Exemption Petition 35

Appendix J

Record of Flight

Date: 

Location: 

Mission:

Pre-flight Inspection: YES NO

Comment:

Weather:

Proximity to airport: 

(see attached map pinpointing approximate location of flight) 

Airport notified: YES NO

Date: 

Time: 

Phone Number: 

Contact Name: 

Nearest major intersection: 

Proximity to medium traffic road: 

Proximity to heavily traveled roadway road: 

Proximity to congested population: 

Weather: Good Fair Poor 

Comment: 

Visibility: Good Fair Poor 

Comment: 

Wind Direction:

Wind Speed (mph):

Comment : 

Approx. takeoff time (local): 

Approx. Landing Time (local):

Estimated Elevation 

Safety Concerns: 

Additional Comments: